Thanks Water and Flyer69 for the excellent advice. I include the following for your entertainment.
I am waiting to hear back from Ms. Chetta. In the meantime, the very professional Chuck Kakuska from Sea K’s Maritime Licensing Service, whom I have dealt with in the past with great results, said “You should be able to utilize NVIC 02-14 to qualify. That was supposed to be the intent of that transition guidelines NVIC otherwise all existing sailors would be penalized because they didn’t get their paperwork in before March 24th.”
So I submitted the following to the NMC:
"I contend that my previous sea time requirements which you have on file at the NMC is sufficient due to the following:
Excerpt from NVIC NO. 02-14 states:
b. The changes to national OSV endorsements include: revisions to sea service
requirements for OSV endorsements to make those requirements comparable to other credentials; providing the option to complete an approved program for a Mate or Assistant Engineer to meet sea service requirements; and adding a progression from vessels less than 1,600 GRT/3,000 GT to more than 1,600 GRT/3,000 GT for chief mate and master. The following endorsements were amended accordingly:
- Master (OSV) [46 CFR 11.493]
- Chief Mate (OSV) [46 CFR 11.495]
- Mate (OSV) [46 CFR 11.497]
- Chief Engineer (OSV) [46 CFR 11.553]
- Assistant Engineer (OSV) [46 CFR 11.555]
c. Until March 24, 2019, mariners who began service or training before March 24, 2014, may qualify for the OSV endorsements listed in paragraph b above, by providing evidence of meeting the previous requirements for the endorsements.
Those requirements are outlined in NMC Policy Letter 07-00 Nov. 14, 2000, which states:
a. Master and mate licenses
(1) A mariner licensed as master or mate 1,600 GRT on ocean or near coastal routes may
have the license endorsed as valid for service on vessels of not more than 3,000 GT. This
endorsement is not limited to service on OSVs. It is included here as a convenient reference
about endorsements that will allow such mariners to serve on OSVs measuring between 1,600 and 3,000 gross tons.
(2) A mariner licensed as master 500 GRT on ocean or near coastal routes may have the
license endorsed as valid for service on OSVs of not more than 3,000 GT on near coastal, domestic voyages.
(3) A mariner licensed as mate 500 GRT on ocean or near coastal routes may have the
license endorsed as valid for service on OSVs of not more than 3,000 GT on near coastal,
domestic voyages.
According to the above policy letters, I held a 500GRT Masters, began service and training, and am referencing sea time accumulated prior to March 24, 2014, therefore I am eligible to receive the 3000 ITC domestic endorsement until March 24, 2019."
Here goes nothing. I’ll keep you updated.